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The conveyance of such mineral interests to Hidrogas Limited shall be for a minimum consideration of Two Million ($2,000,000) Dollars and the President be and the same is hereby authorized and directed to enter into the necessary agreements with Hidrogas Limited in order to complete the transfer of mineral interests and set the terms of payment for same. ...

The issue in this appeal, however, is not so much what the appellant’s primary intention may have been but whether he had, at the time of acquisition of the farm, an alternative or secondary intention of disposing of it under certain circumstances which also constituted a motivating consideration for its purchase. ...

4.3.3 The evidence in the present case is not clear that the amount given by the appellant to pay the debts of her husband was given in consideration of the securities and personal property transferred to her by her husband. ...

Consideration, of course, is given by the Board to the degree of literacy, the schooling and the familiarity with accounting, etc, of each taxpayer. ...

There is no evidence that the appellant even entertained thoughts of real estate sales or development at the time of acquisition of the subject property or that, if he had given any such consideration, it would have been other than the wildest speculation. ...

At the minimum he should receive consideration under the sections of the Income Tax Act allowing for ‘‘restricted farm losses”. ...

Should you have proceeded with the project then the Bank would have given your request for your share of the financing full consideration and we know of no reason why it would not have been granted. ...

BETWEEN: GSW APPLIANCES LIMITED hereinafter called “the Company” OF THE FIRST PART —and— W P UNAITIS hereinafter called “the Executive” OF THE SECOND PART, THIS AGREEMENT WITNESSETH that, in consideration of the mutual covenants and agreements herein contained, the parties hereto covenant and agree each with the other as follows: 1. ...

The Board understands the respondent’s point of view, but believes, however, that it must accept the established facts on the basis of subsection 9(2) of the Tax Review Board Act, SC 1972, c 11: 9. (2) Notwithstanding the provisions of the Act under which an appeal is made, the Board is not bound by any legal or technical rules of evidence in conducting a hearing for the purposes of that Act, and all appeals shall be dealt with by the Board as informally and expeditiously as the circumstances and considerations of fairness will permit. ...

After a full consideration of the evidence adduced, I am unable to detect any error on the part of the Minister in assessing the appellant as he did. ...